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Unless the Department of Energy (DOE) revisits its disposal needs and its current option for disposing of wastes off-site, it could miss opportunities to reduce cleanup costs at the Fernald, Oak Ridge, and the Idaho National Engineering and Environmental Laboratory (INEEL) sites and at other sites, such as Paducah, that might propose the development of new on-site facilities. Building in a decision checkpoint before major investment decisions are finalized could identify instances in which the use of off-site disposal would be less expensive, or when the cost difference no longer outweighs the long-term risks associated with on-site disposal. Such validation of the cost comparison is especially important in instances in which DOE is aware that the scope or timeframe of the cleanup effort has changed dramatically. Remaining open to new proposals for off-site disposal would also inject an element of competition into this process. Thus, even if the validation did nothing more than confirm the original decision to dispose of the wastes on-site, it has the potential to ensure that costs are kept to a minimum.

Recommendations for Executive Action

Status: Closed - Implemented

Comments: In its July 2002 report to Congress entitled "The Cost of Waste Disposal: Life Cycle Cost Analysis of Disposal of DOE Low-Level Radioactive Wastes at Federal and Commercial Facilities," DOE's Office of Environmental Management (EM) reviewed the life-cycle cost estimates to dispose of low-level radioactive waste at six categories of disposal facilities. The categories included DOE's on-site CERCLA facilities at the Fernald, INEEL, and Oak Ridge sites, as well as the commercial Envirocare facility. The report compared the average cost to dispose of a cubic meter of low-level waste to the per-unit life-cycle cost for commercial disposal, and found that DOE's on-site CERCLA disposal cells represent the lowest cost option for waste that is eligible to be disposed in those cells. To estimate disposal costs per unit of waste, the study used waste volumes currently projected for disposal at each CERCLA facility. The report conclusions also noted that the cost estimates are extremely sensitive to disposal volumes, and that, because waste volume projections continue to change, cost estimates should be revisited periodically as cleanup plans unfold. When EM distributed the report to Congress, it issued directions for sites to follow before any existing CERCLA cell is expanded or a new facility built. Those directions required sites to complete a life-cycle cost analysis using cost information developed in the report, and to present the analysis as part of the decision to proceed with expansion or new construction. Taken together, these actions are responsive to GAO's recommendation.

Recommendation: Before constructing new or expanding existing facilities for disposal of cleanup waste at Fernald, INEEL, and Oak Ridge sites, the Secretary of Energy should revisit the cost comparisons for on-site and off-site disposal to determine if the cost estimates used to support the Record of Decision remain valid. If cost advantages for on-site disposal have decreased, the Secretary should reassess whether expected cost savings from on-site disposal facilities outweigh the long-term risks associated with these proposed disposal facilities.

Agency Affected: Department of Energy

Status: Closed - Implemented

Comments: In July 2002, DOE's Office of Environmental Management issued a memorandum that directed DOE field offices to complete a life-cycle cost analysis before expanding any existing CERCLA cell or building a new disposal facility. The memorandum directed that sites complete such analyses using cost information developed in the 2002 report to Congress entitled "The Cost of Waste Disposal: Life Cycle Cost Analysis of Disposal of DOE Low-Level Radioactive Wastes at Federal and Commercial Facilities," and document the analysis as part of the decision to proceed with expansion or new construction. This action is responsive to GAO's recommendation.

Recommendation: DOE should validate cost comparisons at any other sites that may decide to develop an on-site disposal facility.